CHEMICAL MANAGEMENT RESOURCE GUIDE FOR SCHOOL ADMINISTRATORS doc

Printed on Rec
y
cled Pa
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er
United States
Environmental Protection
Agency
Office of Pollution Prevention
and Toxics
Washington, DC 20460
EPA 747-R-06-002
December 2006
| i Chemical Management Resource Guide for School Administrators
Acknowledgements
The time and effort that many individuals contributed to the review and development of this
document is gratefully acknowledged by the U.S. Environmental Protection Agency (EPA). This
document was prepared by Battelle Memorial Institute under contract EP-W-04-021 at the
direction of Mr. Clarence Lewis of the EPA Office of Pollution Prevention and Toxics.

Disclaimer
This document was prepared under contract to an agency of the United States Government.
Neither the United States Government nor any of their employees makes any warranty, expressed
or implied, or assumes any legal liability for any third party’s use of or the results of such use of any
information, product, or process discussed in this document. Mention or illustration of company
or trade names, or of commercial products does not constitute endorsement by the EPA.
As of
the date of this document, external links are current and accurate, and are offered by way of
example only for reference purposes. The EPA is not responsible for content of non-EPA links.
Chemical Management Resource Guide for School Administrators ii |
Summary
“…No one was sure what chemicals were involved in the fire [in the facilities maintenance warehouse at the
school]. Pallets of bleach, ammonia and sulfuric acid based drain cleaner had been stored adjacent to each other,
and rupturing of the chemicals during the fire created an acid vapor cloud as well as chlorine and phosgene gases.
The total cost of this event was about half a million dollars.”
– From a case study of a suburban public high school in New England
1

Are there
Dangerous
Chemicals in
Your
School?
The sources of dangerous
chemicals in schools are not
always obvious. This guidance applies to any
school that purchases, uses, stores, or
disposes of chemicals or products containing
dangerous materials. Some of the most
common dangerous chemical products in
schools include:
• Laboratory chemicals (e.g., acids, bases,
solvents, metals, salts)
• Industrial arts or “shop” classes (e.g., inks,
degreasers)
• Art supplies (e.g., paints, photographic
chemicals)
• Pesticides, fertilizers, and de-icers
• Maintenance supplies and equipment
(e.g., drain cleaners, floor stripping
products, paints, oils, boiler cleaners, fuels,
mercury switches and gauges)
• Health care equipment (e.g., mercury
thermometers).
Who Should Read

This Guidance?
This document is
designed primarily for
school administrators
(principals and other
policymakers), but may also be of value for
teachers, maintenance personnel,
superintendents, school business officials,
insurance industry risk managers, and
parents.
What Can Schools
Do to Prevent
Spills and
Costly Incidents
of Dangerous
Chemicals?
• Establish a leadership team consisting of
qualified and experienced individuals to
oversee chemical management activities
and confirm the availability of budget and
resources (Section III.A)
• Implement pollution prevention and green
chemistry (safer alternatives) principles,
whenever possible, to minimize the use
of hazardous chemicals at schools
(Section III.B)
• Establish a chemical management policy
and chemical hygiene plan (Section III.C)
• Conduct periodic chemical inventories to
identify hazards (Section III.D)

• Establish an environmentally preferable
purchasing policy (Section III.E)
• Implement an appropriate chemical storage
and handling policy (Section III.F)
• Establish a training program for hazardous
chemicals management and safety
(Section III.G)
• Develop a hazard communication plan to
foster awareness among school personnel
and students about the range of chemicals
and products used in schools
(Section III.H)
• Create an emergency response and spill
clean-up plan and ensure that all chemicals
are disposed of in accordance with federal,
state, and local regulations (Section III.I)
| iii Chemical Management Resource Guide for School Administrators
EPA Resources for Additional Information
• EPA, Healthy School Environments,
• EPA’s Schools Chemical Cleanout Campaign (SC3),
• EPA, Where You Live,
What Legal Requirements Do I Have?
Some chemicals purchased by schools may need to be managed as hazardous wastes and may
ultimately require disposal as such. Hazardous wastes need to be managed from their initial point of
generation until their ultimate point of disposal, known as “cradle to grave.” The Resource Conservation
and Recovery Act (RCRA) gives EPA the authority to control the generation, transportation, treatment,
storage, and disposal of hazardous waste. Any school that generates hazardous wastes must notify their
state environmental agency and obtain an EPA Identification (ID) Number. This EPA ID Number must be
put on all manifests for tracking disposal of school wastes and must be site specific for the address given.
School liability does not end when the wastes leave the school, and school administrators must make sure

they receive a copy of the shipping manifest stating that their wastes arrived at their destination (e.g.,
treatment, storage, or disposal facility). Laws and regulations pertaining to RCRA are available at

EPA’s Healthy School Environments Assessment Tool (HealthySEAT) provides information to help
determine if a school is subject to Federal OSHA requirements at
Although Federal OSHA does not have
jurisdiction over state and local government employees, including those in public schools, the 26 states
that operate OSHA-approved State Plans are required to extend their state standards to these workers.
A list of OSHA State-Plan states is located at />101/appena.html#oshasps. Each state’s programs are unique and may have additional regulations and
requirements. In states under Federal OSHA without State Plans, OSHA has no authority to inspect or
enforce standards in public schools; however, the local Federal OSHA office may be able to provide
hazard recognition assistance and technical support. Compliance assistance information is available
on OSHA’s website at .
The National Institute for Occupational Safety and Health (NIOSH) provides a comprehensive safety
checklist program for schools at which contains
recommendations and detailed checklists on OSHA regulations, along with background information on
how to make sense of regulations that may be applicable to schools (
2004-101/chap1.html).
In addition, EPA may enforce certain OSHA standards, such as Hazardous Waste Operations
(29 CFR 1910.120) or relevant EPA standards in public schools. In addition to Federal
requirements, states may have their own laws. Legal requirements are often updated and vary
from state to state. In many states, the health and safety of public employees, including teachers
and other school staff, fall under the jurisdiction of a state agency, such as the state department
of labor or commerce.
Check It Out
Note:
This document is intended
to serve as guidance only
and does not supersede
any federal, state, or

local laws and regulations.
Where Can I Get
Additional Help?
Each EPA Regional Office shares common
chemical management goals; each region has
its own contact point to best serve schools in
their respective states. For more information
on EPA programs for schools, such as EPA’s
Schools Chemical Cleanout Campaign (SC3),
legal requirements that schools may face, and
where your school can receive additional
help, refer to the following regional contact
information and websites in the box below.



Local government entities that may be able
to help your school understand and address
chemical management issues (e.g., treatment
and disposal options) include Local
Emergency Planning Committees (LEPCs),
local health departments, state environmental
departments, and fire departments.
For more information about how local
organizations can help, visit EPA’s SC3 -
Businesses and Community Organizations
website at
Chemical Management Resource Guide for School Administrators iv |
Table of Contents
Page

Summary ii

I. Overview 1
I.A. Introduction 1
I.B. Organization of this Guide 2
I.C. Why You Should Be Concerned 3

II. Hazardous Chemicals and Products in Schools 4

II.A. Chemicals and Products of Concern 4
II.B. Chemical Categories 4
II.C. Where Chemicals and Products are Found 6

III. Policies and Actions 8

III.A. Leadership and Resources 8
III.B. Pollution Prevention and Greener Alternatives 9
III.C. Chemical and Product Management 11
III.D. Chemical Inventory 12
III.E. Purchasing 13
III.F. Storage and Handling 15
III.G. Training 16
III.H. Hazard Communication 17
III.I. Spills, Cleanup, and Disposal 17

IV. Special Cases 20

IV.A. Arsenic 20
IV.B. Asbestos 20

IV.C. Lead 21
IV.D. Mercury 22

V. Conclusion 24


References 25

Appendix A-1
Chemical Hygiene and Management Plans A-1
Sample Guidelines A-3
Checklists A-5
Chemical Purchasing, Storage, and Design Guidelines A-7
Use of Chemicals in Schools A-8

Chemical Management Resource Guide for School Administrators 1 |


EPA has developed a unique software tool to help
school districts evaluate and manage all of their
environmental, safety, and health issues, including
all aspects of their chemical management
programs. The Healthy School Environments
Assessment Tool (HealthySEAT) can be
customized and used, free of charge, by district-
level staff to conduct voluntary self-assessments
of their facilities and to manage information on
environmental conditions within each building.
Source: EPA, HealthySEAT,

healthyseat/index.html

I. Overview
I.A. Introduction
From elementary school maintenance storage
closets to high school chemistry laboratories,
schools house a variety of chemicals. Many
of these chemicals are hazardous and are
used daily; however, in some cases, these
chemicals have been unused for decades.
Ensuring that these chemicals are managed
properly will help school administrators to:
safeguard the health and safety of students
and school employees; avoid disposal
expenses and costly school closures associated
with spills and emergency incidents; maintain
a sense of trust between the district and the
surrounding community; and prevent damage
to the environment. School districts need
solid, useful, specific recommendations and
information on responsible chemical
management to facilitate the establishment of
sound district-level policies and procedures.
This document is intended to aid K-12 public
school districts and private, religious, and
independent schools and school system
policymakers in reducing dangerous chemical
use and implementing responsible chemical
management practices. Institutionalizing
such practices will help to minimize the

incidence of chemical spills, exposures, and
emergency scenarios in schools. This
document focuses on broad policy
considerations that EPA recommends school
administrators consider implementing to
properly manage and use all dangerous
chemicals. Parents and others in the
community interested in school health
and safety policies also may use this booklet
to determine whether their children’s schools
are effectively minimizing potential exposure
to dangerous chemicals and products.
This document is part of EPA’s Healthy
School Environments Initiative. The
Healthy School Environments website
( serves as a
gateway to on-line resources to help school
administrators, teachers, facility managers
and other staff, and parents address
environmental health issues in schools.
This document is also an integral part of the
EPA Schools Chemical Cleanout Campaign
(SC3) toolkit. The goals of the SC3 are to:
remove potentially harmful chemicals from
schools; emphasize the implementation of
preventive programs such as chemical
management training for lab instructors and
microscale techniques; and raise national
awareness of the issue of chemicals in
schools. The ultimate goal of the SC3 is

to create a chemically safer school
environment in which chemicals are
purchased wisely, stored safely, handled by
trained personnel, used responsibly, and
disposed of properly. Finally, this document
includes numerous boxes highlighting
information on relevant EPA and state
information, such as the HealthySEAT tool
developed by EPA as a resource to address
chemical management among other
environmental, safety, and health issues.

| 2 Chemical Management Resource Guide for School Administrators
I.B. Organization of this Guide
Section I explains the need for responsible
chemical management policies and why
school administrators must be concerned
about chemical management in their schools.
Section II provides an overview of the
various classes of hazardous chemicals and
products of concern found in schools, and
discusses where these chemicals and
products of concern might commonly be
found in schools.
Section III presents recommendations for
school administrators to develop their own
consistent and effective policies, promotes
concepts such as pollution prevention and
green chemistry, and provides information
on best practices for the purchase,

identification, tracking, storage, use, and
disposal of hazardous chemicals found in
elementary and secondary schools.
Section IV discusses special types of
chemicals that are of particular concern.
Section V presents conclusions.
The Appendix lists specific examples of
various “how to” forms, templates, and
checklists for establishing policies and
procedures that schools may use to
facilitate the implementation of EPA’s
recommendations.
This document contains numerous
references and endnotes to school-focused
guidance documents and materials on
chemical management, green chemistry,
pollution prevention, environmentally
preferable purchasing, and school cleanout
campaigns initiated in school districts. For
example, the Los Angeles Unified School
District, one of the largest school districts in
the country, along with its home state of
California, have been committed to spreading
awareness about chemicals in schools, as
illustrated below.

The Los Angeles Unified School District (LAUSD) has been particularly active on issues related to chemicals in
schools. The LAUSD’s Office of Environmental Health and Safety (OEHS) website contains a wealth of resources
for school officials, including a searchable product review tool available on the OEHS Chemical Evaluation Program
page ( />) and comprehensive information about its Chemical

Hygiene Program. The OEHS Chemical Hygiene Program page ( />)
contains links to various handouts and the Science Safety Handbook for California Public Schools (sd-
oehs.org/docs/Misc/CAScienceSafetyHandbook.pdf). It also lists chemicals approved by the State of California and
OEHS for use in LAUSD school laboratories. These chemicals can be viewed by clicking the “View Approved
Laboratory Chemicals” button on the OEHS Chemical Hygiene Program page (listed above).
The State of California has customized EPA’s HealthySEAT software to incorporate California’s regulations and
links to other state-specific information, including funding sources. State-customized versions of HealthySEAT make
it easier for individual school systems to adapt and use the tool.

Chemical Management Resource Guide for School Administrators 3 |
1
2
3
4
5
I.C. Why You Should Be
Concerned
There are five key reasons why school
administrators should be concerned about
chemical management in their schools:
Improper chemical management
poses health and safety risks to students
and school employees. Health, learning,
and behavior risks to students are
of particular concern, as children are
more vulnerable than adults to chemical
exposures because their bodily systems are
still developing; they eat more, drink more,
and breathe more in proportion to their
body size; and their behavior can expose

them more to chemicals than adults.
The expenses incurred from disposal,
spills, and other incidents, including
potential liabilities/lawsuits, can
be considerable. The costs of
responding to chemical incidents can
reach hundreds of thousands of dollars or
more at a single school.
2
In addition to
response costs, improper chemical waste
management can result in fines and
increased insurance premiums.
It only takes one chemical incident,
such as a spill, explosion, or
chemical exposure, to break the trust
with the community. Reported school
incidents can lead to increased parental and
community concern, negative publicity,
and embarrassment to the school and
school district.
Improper chemical management
may result in school closures that
result in a loss of valuable education
time.
Improper chemical management
can lead to unintended chemical
discharges and spills, which inflict
damage upon the environment where
students, teachers, staff, and parents live

and work. Improper chemical discharges
into sanitary sewer lines or on-site waste
treatment systems (including septic tanks)
can have adverse effects on rivers, streams,
and groundwater. Chemical releases and
spills can also contribute to air pollution.
Spills to the ground can ultimately result
in long-term harm to the land and
considerable remediation costs.
A safe school environment that prevents
harm to students and protects school
employees from dangerous chemicals must
be promoted. Responsible chemical
management is likely to lead to improved
learning in the classroom and improved
overall health of the environment and the
community.
| 4 Chemical Management Resource Guide for School Administrators
II. Hazardous Chemicals and Products
in Schools
II.A. Chemicals and Products
of Concern
Approximately 75,000 chemical substances
are in commercial use today.
3
Many of these
chemical substances are considered toxic or
otherwise hazardous to humans and other
living beings. Toxic chemicals are associated
with a variety of serious health problems,

including cancer, brain and nervous system
disorders, reproductive disorders, organ
damage, as well as asthma. Toxic chemicals
that are persistent in the environment and
bioaccumulate through the food chain can
make exposure during childhood and
adolescence especially dangerous. Chemicals
also can irritate the skin, eyes, nose, and
throat. Some chemicals pose significant
safety hazards, such as fire or explosion risks.
Many hazardous chemicals can be found in
school facilities. Material Safety Data Sheets
(MSDS), comprehensive fact sheets prepared
by chemical manufacturers, describe the
physical properties, health effects, and
other characteristics of chemicals, as well as
procedures for handling, storing, and
disposing of these substances.
4
Chemical
manufacturers should supply MSDSs along
with each shipment of chemicals delivered to
your school. The proper use and
management of these substances, as well as
the products that contain them, are critical to
maintaining a healthy atmosphere for school
occupants and the surrounding environment.
The term “hazardous chemicals” may include
(but is not limited to) the following:
• Laboratory chemicals used or stored in

science laboratories and preparation areas;
• Art supplies, including paints, stains, inks,
glazes, and photo processing chemicals,
used in (visual and performing) art and
shop;
• Cleaning products utilized by custodial,
cafeteria, and maintenance staff;
• Pesticides, fertilizers, and de-icers/salts/
sands used for grounds maintenance,
as well as pesticides used for building
maintenance;
• Paints, solvents, fuels, degreasers, and
lubricants used in building operation and
maintenance;
• Oils, fuels, paints, antifreeze, and other
chemicals used to maintain and repair
equipment for transportation, school
maintenance, and shop classes;
• Inks, solvents, and adhesives used for
printing in school offices; and
• Chemicals used to treat water associated
with drinking water and swimming pools.
II.B. Chemical Categories
Chemicals can be grouped based on the type
of hazard they pose. Understanding the
different types of chemicals in a school is
important for developing an effective
chemical management policy. Hazardous
substances in schools may fall into one or
more of the following categories:

flammables/explosives, corrosives (the
majority of which in high school laboratories
are acids and bases), oxidizers/reactives,
toxi
cs, and compressed gases. Federal
agencies and legislative authorities have
developed specific definitions for each of
those categories; however, the hazards can be
described generally as follows:
5
The risks associated with exposure to a
chemical are dependent on many factors, including
the chemical’s hazard level (degree of flammability,
toxicity, etc.), the route of exposure (e.g., absorbed
through skin, inhaled, consumed, injected), and the
duration of exposure.

Chemical Management Resource Guide for School Administrators 5 |

Chemical Type Description and Examples
Flammables/
Explosives


Chemicals that have the potential to catch fire rapidly and burn in the air. Liquids, gases,
and solids (in the form of dusts) can be flammable and/or explosive.
Examples: paint thinner; laboratory solvents (acetone, alcohols, acetic acid, hexane);
adhesives (some)
Corrosives

Chemicals that can burn, irritate, or destroy living tissue or corrode metal through direct
chemical action. This category includes strong acids and bases (alkalines), as well as
dehydrating agents and oxidants.
Examples: sulfuric, nitric, and hydrochloric acids; potassium, ammonium, and sodium
hydroxides (bases); hydrogen peroxide or chlorine (oxidants); acetic acid
Oxidizers/
Reactives


Chemicals that react violently when combined with heat, light, water, or atmospheric
oxygen, causing explosions or violent chemical reactions.
Examples: nitrates; chlorates; nitrites; peroxides; picric acid (crystallized); ethyl ether
(crystallized); water reactive metals (e.g., sodium)
Toxics


Any substances that, even in small amounts, can injure living tissue when ingested,
inhaled, or absorbed into the skin.
Examples: mercury; arsenic; lead; asbestos; cyanide
Compressed
Gases


Gases stored under high pressure such that cracks or damage to the tanks and valves
used to control these gases could cause significant physical harm to those in the same
room.
Examples: acetylene; helium; nitrogen

Improper storage practices may increase the risks associated with certain chemicals, particularly those that are flammable,
corrosive, or reactive. The King County Laboratory Waste Management Guide (
publications/LabGuidelinesRevAugust06.pdf)
provides suggestions for safe and effective chemical storage, including shelf
storage patterns for small stockrooms (see Table 1).

EPA’s “No More ‘Methyl Something’: Improving Management of Curriculum Chemicals in Schools” presentation provides
examples of dangerous storage scenarios:
Check It Out
| 6 Chemical Management Resource Guide for School Administrators
II.C. Where Chemicals and
Products are Found
Chemicals can be found throughout a school.
They are used in both the maintenance of
schools and the curriculum taught.
Chemicals help students to perform
experiments and learn new skills, among
other benefits. In the absence of chemicals,
schools would lack certain fundamental tools
needed to educate students. Despite their
useful purposes, chemicals can be dangerous
to students and staff when managed
improperly. Hazardous chemicals are found
in classrooms, laboratories, storerooms,
maintenance sheds, and numerous other
areas. High schools usually have larger
inventories and more hazardous chemicals
than middle and elementary schools.
Chemicals may have been purchased by the
school or brought in by employees or

students for their personal use.
The table on the following page lists some
specific locations in which chemicals and
products of concern might be found in a
typical school. Please keep in mind that this
list is by no means all-inclusive, and that
chemicals, when used appropriately, can be
important to the educational process.







Types and Locations of Hazardous Chemicals/Products in Schools:
• EPA, Chemical Management and Usage,
ehsstudy/ehs1.htm and “No More ‘Methyl Something’: Improving Management of Curriculum Chemicals in
Schools,”
• Colorado Department of Public Health and Environment, One Hundred Most Commonly Found Explosive
and Shock-Sensitive Materials, www.cdphe.state.co.us/cp/Institutions/Schools/ChemsInSchools/
ExplosiveTop40.PDF
Alternatives to Products of Concern:
• EPA, Environmentally Preferable Purchasing, Environmentally
Preferable Purchasing Program, Product and Service Information,
• Maryland State Department of Education, Safety in Ordering, Storing, Using and Disposing of Chemicals,

Check It Out
Hazardous chemicals are found in classrooms, laboratories,
studios, maintenance areas, and numerous other areas.

The photo above depicts one location where chemicals and
products of concern might be found in a typical school. This photo
also demonstrates a properly organized chemical storage area.
Photo Credit: Rehab the Lab Program,
Local Hazardous Waste Management.
King County, Washington
Chemical Management Resource Guide for School Administrators 7 |

Location Product Type
Hazardous Ingredient
Examples
Concentrated Acids (undiluted)
Hydrochloric acid
Nitric acid
Concentrated Bases (undiluted) Sodium hydroxide
Solvents
Methanol
Methylene chloride
Oxidizers Lead nitrate
Compressed gases Oxygen
Science laboratories
Toxics
Cyanides
Chromates (VI)
Lead salts
Mercury salts
Solvents (used in paints, paint thinners, adhesives, lacquers,
primers, and other products)
Petroleum naphtha
Turpentine

Cleaning supplies/detergents
Phosphoric acid
Sodium silicate
Compressed gases
Acetylene
Nitrogen
Vocational and
trade shops (can also be
referred to as Career and
Technical Education)
Fuels, transmission, and brake fluids Gasoline
Solvents (used in paints, inks, paint thinners, adhesives,
lacquers, primers, and other products)
Toluene
Mineral spirits
Pottery clear coating glaze
Lead
Other heavy metals
Pigments for paints and coatings
Cadmium
Manganese
Chromium
Dry clay for ceramics and jewelry Silica
Visual and
performing art studios
Acids for etching
Nitric acid
Hydrochloric acid
Cleaning supplies/detergents
2-Butoxyethanol

Trisodium phosphate
Drain cleaners (alkaline)
Drain cleaners (acidic)
Potassium hydroxide
Sulfuric acid
Pesticides (including disinfectants/sterilizers)
Permethrin
Sodium hypochlorite
Paint thinners Toluene
Solvents (used in paints, paint thinners, adhesives, lacquers,
primers, and other products)
Xylene
Custodial/maintenance
areas
Water treatment chemicals for swimming pools Chlorine tablets
Pesticides (including disinfectants/sterilizers)
Permethrin
Sodium hypochlorite
Refrigerants
CFCs
Ammonia
Kitchens/cafeterias
Cleaning supplies/detergents Ammonium hydroxide
Nurses’ offices Medical equipment
Mercury (thermometers and
blood pressure manometers)
Intensifiers/reducers
Potassium dichromate
Hydrochloric acid
Developers

Hydroquinone
Lactic acid
Photography laboratories
Stop baths and fixer
Acetic acid
Chrome alum (potassium
chromium sulfate)
Pesticides 2,4-D
De-icers Sodium chloride
School grounds/
athletic fields
Fertilizers Ammonium nitrate
Correction fluid
Ethylene glycol
Trichloroethane
Solvents (used in paints, inks, paint thinners, adhesives,
lacquers, primers, and other products)
Methyl ethyl ketone
Petroleum distillates
Administrative offices
Printer/copier toners Carbon black

| 8 Chemical Management Resource Guide for School Administrators
Training and Teamwork Approach
to Safety and Chemical Hygiene
“Northshore School District, in Washington State,
has adopted the training and teamwork approach to
Safety and Chemical Hygiene in the past 2 years.
As a result, last year our insurance pool lowered our
annual insurance premium by $30,000 for our efforts.

In enacting these programs our Director of Curriculum,
Director of Risk Management, and the Chemical Hygiene
Officers saved money for the district.”
John Schmied,
Northshore
School District
Chemical Hygiene Officer


III. Policies and Actions
The following sections provide guidance on
recommended chemical management policies.
These policies relate to: pollution prevention
and green chemistry (concepts that minimize
the potential for hazardous chemical use in the
first place); the general management of
chemicals and products already present in
schools; chemical inventories; the purchasing
and tracking of chemicals; the storage and
handling of hazardous chemicals; personnel
training and hazard communication; and
chemical spills, cleanup, and disposal. To
properly implement these suggested policies,
schools should establish a leadership team and
confirm the availability of budget and
resources.
III.A. Leadership and
Resources
To institute good chemical management
policies, school administrators need to set the

tone that chemical management is important
by assigning roles and responsibilities for
implementing proper safety and chemical
hygiene practices. Guidelines are provided
below that policymakers at the district level
and school administrators should implement
in order to initiate responsible chemical
management practices in their schools.
• Establish or confirm that your district
has committed budget and staff
resources for chemical management.
When schools consider their costs for
chemicals, they generally consider only the
purchase price. Each stage of chemical
and product management, however, has
associated costs of labor (e.g., training
chemical hygiene officer and other staff),
materials, equipment, and disposal, as well
as costs of storage space and potential
liability when responsible chemical
management is not practiced.
• Design and communicate a chemical
management policy. School district
administrators and principals need to
establish an overall policy stating a strong
commitment to responsible chemical
management, including implementation of
the policies and actions defined in this
document. The policy should be
communicated to all by the highest level of

management. Strong support from the
administration, combined with adequate
resources, will enable responsible chemical
management. Active involvement by the
full school community is an important
element of success, as well.
• Appoint a chemical hygiene officer.
The chemical hygiene officer is someone
who is qualified by training and experience
to provide technical guidance and
leadership in the development and
implementation of the provisions of the
chemical hygiene plan. T he position
description or job classification of a
chemical hygiene officer will vary across
school districts; however, in all cases, they
should be trained to provide chemical
management leadership to the school.
• Designate a team to oversee the
chemical management program at your
school. This team should consist of
teachers, janitorial staff, and maintenance
personnel to comply with the chemical
hygiene plan and help oversee the chemical
Chemical Management Resource Guide for School Administrators 9 |
management program at your school
described in the sections that follow.
Team members should be trained by the
chemical hygiene officer (and reinforced
at least annually). At a minimum, team

members should understand physical/
chemical properties and potential
health effects of chemicals, chemical
compatibility, applicable environmental
regulations and compliance issues, and
waste management procedures of the
school. You may also consider involving
students (as applicable) as part of the
process.
• Disseminate information. Share
experiences and lessons learned with other
school districts and administrators.
Maintain a proactive program of informing
parents, guardians, teachers, and other staff
about chemical and product management
activities ongoing at your school.
III.B. Pollution Prevention and
Greener Alternatives
A key aspect of responsible chemical
management is identifying opportunities
to minimize chemical use through the
implementation of pollution prevention
and green chemistry principles.

Pollution prevention (sometimes referred to
as “P2”) is defined as preventing or reducing
pollution at the source, whenever feasible,
and other practices that replace or eliminate
the creation of pollutants. An example of
pollution prevention would be using smaller

quantities of (or environmentally benign
substitutes for) chemical products used for
grounds maintenance or cleaning.
A related concept, green chemistry, focuses
on science laboratories by reducing the levels
of toxicity and amount of chemicals used in
experiments, promoting safety, pollution
prevention, and waste minimization. Similar
concepts, microscale chemistry and small-
scale chemistry, involve scaling down the
quantities of chemicals required for science
experiments resulting in improved laboratory
safety. Exploring and adopting pollution
prevention and green chemistry concepts in
a school system results in many direct
environmental benefits and often results in
cost savings for schools.
The following guidelines can be used to
reduce or eliminate the generation of
chemical pollutants and wastes.
• Establish a policy that makes pollution
prevention the preferred form of waste
management and strives to eliminate the
purchase and use of most, if not all,
hazardous chemicals. If elimination of the
particular chemicals is not possible, other
options include, in order of preference,
reuse or recycling of chemicals and
products; treatment of chemicals to reduce
toxicity; and disposal of chemicals in an

environmentally safe manner.
While treatment may be a useful activity, it should be cautioned that the treatment of hazardous waste may require
a permit or be subject to regulation. You should consider discussing any treatment options with state or local
regulatory agencies before you implement them in your laboratory. Neutralization of acids and bases, permitted
under federal law, is probably the most commonly used treatment method in educational institutions; however,
states may have more stringent standards regulating the disposal of acids and bases. To learn more about
treatment methods, see Battelle Seattle Research Center’s “In-Laboratory Treatment of Wastes,” available on the
P2 Pays website at
Check It Out
| 10 Chemical Management Resource Guide for School Administrators
The following resources provide technical background information to help schools implement their
own pollution prevention/waste minimization programs:
• Ohio EPA, Laboratory Pollution Prevention fact sheet,
and P2 checklist of lab opportunities,
• Battelle Seattle Research Center, Laboratory Waste Minimization and Pollution Prevention: A Guide for
Teachers, and Chapter 8, Scaling Down Experiments,
/>
• EPA, Pollution Prevention: Definitions,
• EPA, 12 Principles of Green Chemistry, and Teachers,

• EPA, state P2 Programs,
• EPA, Integrated Pest Management (IPM) in Schools,
• EPA’s Schools Chemical Cleanout Campaign (SC3),
• Great Lakes Regional Pollution Prevention Roundtable, Topic Hub™ for Pollution Prevention for Arts Education,

• Green Cleaning Pollution Prevention Calculator,
• Colorado State University, National Small-Scale Chemistry Center,
• Merrimack College, National Microscale Chemistry Center,
•
Contact your state pollution prevention

department for assistance in conducting
a pollution prevention opportunity
assessment, or contact your EPA Regional
Office at
local.htm to find programs available in
your area as well as the issues affecting
your part of the country. Each EPA
Regional Office supports pollution
prevention activities that reduce or
eliminate the sources of waste and
pollutants through work with voluntary
programs, partnerships with business
and industry, state and local governments,
citizens groups and other federal agencies.
• Establish a pollution prevention program
to help your school minimize the amount
of chemical waste generated throughout
your school. The program may consist of
developing school-wide and departmental
annual waste reduction goals. The
program may also include pollution
prevention education sessions for teachers,
maintenance staff, and students
emphasizing the importance of substituting
hazardous chemicals with chemicals that
are less hazardous and scaling down the
volume of chemicals used in classroom
experiments and maintenance applications.
• Minimize the use of pesticides, a term that
refers not only to insecticides but also to

herbicides, fungicides, and various other
substances used to control pests. Children
may be especially sensitive to the health
risks posed by pesticides because their
bodies are growing and developing; they
may also have greater exposure to
pesticides because of their increased hand-
to-mouth behaviors. A form of pollution
prevention, integrated pest management
(IPM), is an effective and environmentally
sensitive approach to pest control that
relies on common sense strategies to
disrupt the life cycles of pests.

Chemical Management Resource Guide for School Administrators 11 |
EPA’s Schools Chemical Cleanout Campaign
Resources such as EPA’s SC3 program (see
are designed to facilitate chemical
and product management. The purpose of SC3 is to
reduce chemical exposures and improve chemical
management in K-12 schools. By achieving these
environmental goals, the SC3 will contribute to the broader
goals of fewer lost schools days and healthier students,
faculty, and staff.
In addition to EPA’s SC3, states have developed their own
SC3 programs:
• Florida Department of Environmental Protection, School
Chemical Cleanout Campaign (SC3),
/>ages/schoolchemicals.htm; and
• Tennessee Department of Environment and

Conservation, School Lab Chemical Cleanout Campaign
(SC3),
III.C. Chemical and Product
Management
Responsible chemical management is critical
to controlling a variety of environmental,
health, and safety issues within any school.
Knowing what materials are present in your
school and how they are used, stored, and
discarded will enable you to understand the
issues associated with these substances.
Properly recognizing and controlling the
hazards inherent to these materials, wherever
they are found in your schools, will enhance
your ability to create a safe school with
minimal environmental liabilities/lawsuits.
Guidelines are provided below that
schools and administrators should implement
to initiate responsible chemical management
practices in their school.
• Establish an environmentally preferable
chemical management policy considering
the entire chemical and product lifecycle,
which begins with chemical purchasing and
includes identification, labeling, storage,
inventory maintenance, and the activities
associated with the use and disposal of
chemicals and wastes generated from their
use, including training, spill control
procedures, and record-keeping

requirements.
• Establish a district-level chemical
purchasing policy, chemical products
evaluation process, and a district-approved
chemicals and products list (see Section
III.E). For example, the Los Angeles
Unified School District’s Chemical
Hygiene Program (sd-
oehs.org/chemical-hygiene.asp) allows only
approved chemicals to be used in school
laboratories. Controlling what chemicals
are used within your schools is essential to
ensuring that only products that have been
reviewed and approved for use are brought
into the school environment.
• Create a written chemical hygiene plan that
describes procedures and practices for the
protection of students and school
employees from the health hazards
presented by hazardous chemicals and
products that are found in school
laboratories. The chemical hygiene plan is
a critical element of chemical management
and should contain specific requirements
and guidelines for chemical handling,
inventory, storage, spills, and disposal.
The plan should be updated annually and
whenever necessary. The Appendix
contains excerpts and references to several
examples of chemical hygiene plans

Chemicals that are not correctly and clearly
labeled, as shown in the photos above,
should be disposed of properly. Products
used in schools should have an MSDS, be
stored in their original containers, and be
correctly and clearly labeled.
Photo Credit: Rehab the Lab Program,
Local Hazardous Waste Management
King County, Washington
| 12 Chemical Management Resource Guide for School Administrators
Chemical Inventory Safety Tips
The process of assessing existing chemical hazards can be
dangerous. The following guidelines are recommended:
• Contact a trained professional to conduct a walk-through
inspection of the school to pre-screen for potential
hazards. Certain types of chemicals pose an imminent
hazard (e.g., shock-sensitive materials) and must be
handled only by qualified emergency personnel or
hazardous waste professionals.
• If the pre-screening establishes that it is safe to conduct
an inventory, ensure that the inventory team is properly
equipped with personal protective equipment and
emergency response supplies as well as chemical
management and safety knowledge.
• Ensure that chemical storage areas are properly
ventilated and that potential sources of ignition are
turned off.
• Conduct pre-screening, inventory and removal while
students are NOT in school.
• When complete, provide your local fire department a

copy of the chemical inventory.
Appendix 2 of the Massachusetts School Chemical
Management Program (available at
dep/service/schlchem.pdf) includes a step-by-step guide to
conducting chemical inventories.
currently in use by school districts
nationwide.
• Contact state or local health departments
or environmental agencies for more
information. Many chemical management
practices are often regulated at the federal,
state, and/or local level.
III.D. Chemical Inventory
Existing accumulations of outdated,
unknown, poorly labeled, improperly stored,
degraded, and excessive quantities of
hazardous chemicals are present in many
schools. These chemicals pose safety and
health risks to students and school personnel.
Properly identifying and removing these
chemicals is a key step in preventing
accidents. An important part of responsible
chemical management is the creation of an
accurate chemical inventory. A chemical
inventory identifies the quantities and
physical locations of, as well as the potential
hazards associated with, all of the chemicals
used and stored in a school. It also serves
as a reference for school and emergency
personnel (e.g., local fire department) in

the event of an emergency. Furthermore,
a chemical inventory, when used to guide
necessary purchases, can reduce the costs and
management needs associated with excess
chemicals.
Guidelines are provided below that
schools and administrators should follow in
order to conduct an inventory at their school.
Some guidelines refer to other documents
(e.g., chemical hygiene plans); information
about these documents is discussed in later
sections.
• Conduct an inventory of all of the
chemicals and products containing
chemicals (e.g., mercury thermometers)
stored on-site, covering all sections of the
school including maintenance rooms and
closets, storage sheds, greenhouses, and all
A
chemical inventory identifies the amount and location
of all of the chemicals stored on-site, covering all
sections of the school including maintenance areas.
A thorough inventory would identify inappropriate
chemical storage practices, such as the one shown in
this photo. Chemicals such as ammonia and bleach
are commonly found in schools. Despite their useful
purposes, these chemicals are incompatible and
should not be stored near each other, especially in
maintenance storage areas or in hot boiler rooms where
the bottles may bulge or break. Mixing of these two

chemicals would create a chlorine gas cloud.
Photo Credit: Marina Brock, Barnstable County
(Massachusetts) Department of Health and
Envir
o
nm
e
n
t

Chemical Management Resource Guide for School Administrators 13 |
classrooms. Engage all school staff who
will either be involved in conducting the
inventory, or will be having their chemicals
inventoried. Pre-packaged science
experiments or demonstration kits should
be included in the chemical inventory.
• Establish a policy that chemical inventories
be conducted and updated annually, unless
state or local regulations require a more
frequent schedule. Contact your local state
agency, college or university, industry
partner, or chemical supplier, or identify
a responsible person within the school
who has training in hazardous chemical
management to assist with the inventory.
• Review other documents you may have in
schools in your district, such as a chemical
hygiene plan or hazard communication plan, to
ensure that chemicals are consistently

being managed, stored, handled, and
disposed of properly. Review your approved
chemicals and products list (see Section III.E).
Chemicals and products not on this list
should be removed and properly disposed
of or recycled according to applicable
federal, state, and local laws. Update the
inventory when new chemicals or products
are added to the list and when chemicals or
products are used or disposed.
• Conduct periodic cleanouts by identifying
and removing unnecessary hazardous
materials and expired chemicals through
appropriate recycling and/or disposal
methods. Chemical inventories should be
conducted prior to cleaning out chemicals
from schools. Contact your local state
agency, college or university, industry
partner, or chemical supplier, or someone
with technical qualifications to identify
potentially dangerous situations (i.e., school
staff should not move very old chemicals
because of the extreme hazard they may
present) and properly handle the chemicals
during a chemical cleanout.
III.E. Purchasing
Chemicals enter school systems through
a variety of avenues such as regular purchases
(including purchase orders, purchasing cards,
and personal purchases) by teachers and

facility maintenance personnel, as well as
donations from local industries and chemical
suppliers.
Chemicals have varying hazard levels; thus,
the determination to purchase should factor
in need, use, safety, environmental factors,
and chemical/product management lifecycle
costs. Remember, just because a chemical
can be purchased at your local hardware or
grocery store does not mean it is safe if
improperly used or stored.
To create a chemically safer school
environment, school administrators should
implement measures to reduce the amount
and hazardous nature of chemicals entering
their schools. Perform small-scale or
microscale chemistry experiments or seek
environmentally preferred products or
services “that have a lesser or reduced effect
on human health and the environment when
compared with competing products or
services that serve the same purpose.”
6



The following resources provide information to
help schools conduct their own chemical
inventories, including a suggested chemical
inventory list. You may also wish to check with

your own state’s environmental and educational
agencies.
• Colorado Department of Public Health
and Environment, Guidance on
Chemical Management in Schools,
/>Schools/ChemsInSchools/ChemMgmt.html
• Montana Department of Environmental
Quality, Montana School Labs,

Check It Out
| 14 Chemical Management Resource Guide for School Administrators
Environmentally Preferable Purchasing
EPA’s Environmentally Preferable Purchasing (EPP)
program was developed to assist federal agencies in
making environmentally conscious purchasing decisions;
however, businesses and state and local agencies have
also found the program to be of value. The EPP website
(
discusses frequently asked questions concerning EPP
and includes a number of tools and links to guidance
documents and case studies that schools can use to
identify products that are less hazardous.
Here are some suggestions of best
management practices to create a
chemically safer school environment:
• Establish a purchasing policy that
addresses how chemicals and products
containing chemicals are entering a school,
who is using them, why they are being
used, and how they will need to be

disposed. Involve all teachers,
maintenance and custodial personnel, and
other staff to ensure that the chemical
purchasing policy meets educational and
facility maintenance needs while reducing
the quantities and toxicity of chemicals.
The Appendix provides resources to
chemical purchasing examples in schools.
• Investigate pollution prevention and green
chemistry options (see Section III.B) to
determine whether certain chemicals can
be reduced in quantity or eliminated
entirely from science and art classes.
• Establish an environmentally preferable
chemical screening process to ensure that
all chemicals and products containing
chemicals have been screened for
environmental, health, and safety hazards
prior to purchase, thus reducing and/or
eliminating hazardous chemicals.
For example, the Maryland State
Department of Education provides
guidance on responsible chemical
purchasing.
7
The MSDS may be useful
in this process.
• Create an approved chemicals and
products list, based on less toxic or non-
toxic alternatives to make non-toxic

implementation and enforcement easier
in your school. Only allow procurement of
approved chemicals.
• Purchase chemicals and products
containing chemicals in quantities that will
be used during the current school year or
that can be fully consumed under normal
conditions within the shelf life of the
product. Another concept is “just in time”
purchasing in which chemicals are
purchased as needed throughout the
school year. These purchasing methods
reduce the costs and management needs
associated with excess and expired
chemicals.
• Use products purchased or approved by
the school. Teachers and other staff
should be strongly discouraged from
bringing in products on their own.
Products used in schools should have
an MSDS, be stored in their original
containers in a secure location, and be
correctly and clearly labeled.
Schools should exercise
EXTREME CAUTION when accepting chemical
donations, product samples, or promotional products
(e.g., do not accept chemicals more useful for
electroplating than for the teaching of high school
chemistry). Schools should not give away chemicals
to avoid the costs of disposal.

Chemical Management Resource Guide for School Administrators 15 |
A few school districts have developed their own chemical
hygiene plans that provide step-by-step procedures, as well
as checklists for the safe handling and storage of
chemicals.
• Northshore School District Chemical Hygiene Plan,
/>ook/default.php?cms_mode=view&sectiondetailid=58540
&sc_id=1161987494
• Lake Havasu Unified School District, Arizona District
Chemical Hygiene Plan, asu.k12.
az.us/support/warehouse/chempolicy.html
• LAUSD, School Laboratory Chemical Hygiene and Safety
Plan (Appendix F),
CSC/Chemical%20Hygiene%20Plan.pdf
III.F. Storage and Handling
School administrators should be aware
of proper use and storage policies
and procedures to ensure student and
employee safety. Guidelines are provided
below that schools and administrators can
follow in order to reduce the risk of chemical
accidents and ensure that chemicals and
products in their schools are stored and
handled safely.
• Establish a chemical storage and handling
policy that addresses how chemicals should
be properly stored, labeled, and secured, as
well as who should have access to these
chemicals and chemical storage locations.

Chemicals should not be stored in areas
that are occupied by or accessible to
students, such as classrooms or restrooms;
they should preferably be stored in a
central, secure location. The Appendix
provides resources to guidelines on the
proper labeling of chemicals,
recommended storage methods, and other
considerations for proper storage (e.g.,
examples of incompatible chemicals and
chemical segregation).
• Conduct at least annual inspections of
classrooms, janitorial closets, and chemical
storage rooms and cabinets in your school
to ensure the integrity of chemicals and
storage structures. Spot inspections may
be performed periodically throughout the
school year. Engage maintenance staff in
these inspections if storage shelving or
locks are in need of updates or repair.
Create and maintain an up-to-date map
of the location and storage pattern of
chemical storage rooms and cabinets in
your school.
• Inspect and test emergency equipment
(e.g., eyewash stations and safety showers)
as well as fume hoods and ventilation
systems/exhaust fans at least on an annual
basis. Engage maintenance staff in these
inspections if safety equipment is in need

of updates or repair. Establish protocols
for the upkeep of emergency equipment
and the associated maintenance records.
• Work with a local chemical supplier to
ensure you have MSDS information for all
chemicals on site. Hazardous chemicals in
schools should be stored in accordance
with MSDS specifications. Maintaining
a hard copy or secure website access to
MSDS information at the district level
could be a cost-effective approach to
ensuring that chemical safety information
is available across all schools. At a
minimum, MSDS information should be
located in all chemical storage rooms and
cabinets and in a central place within the
school (away from the chemicals), as well
as a central location for the school district.
To avoid a situation like the example shown above,
schools should establish a chemical storage and
handling policy that addresses how chemicals should
be properly stored, labeled, and secured, as well as
who should have access to them.
Photo Credit: Rehab the Lab Program,
Local Hazardous Waste Management,
King County, Washington


| 16 Chemical Management Resource Guide for School Administrators
III.G. Training

Proper training of staff and students on
the handling of chemicals and products
containing chemicals will help prevent
accidents, thus reducing exposure to harmful
chemicals. Training at various levels should
be provided for all school employees and
students on basic chemical hygiene, storage
and handling procedures, and how to
respond in the event of a chemical spill or
accident. Guidelines are provided below that
schools and administrators should follow on
training.
• Establish a hazardous chemicals
management and safety training program
that addresses how school employees (and
students, as applicable) are to be properly
trained to handle certain chemicals and
products and how to respond to a chemical
spill or release, to understand the hazards
of these materials, and to understand the
types of liability associated with accidents
involving chemical usage in schools.
Targeted employees should include school
management, custodial and maintenance
personnel, and appropriate teaching staff.
The training program should include a
review of the chemical hygiene plan,
hazard communication plan, and approved
products listing. Training sessions should
be documented in a log for each employee

and repeated periodically (e.g., on an
annual basis) to serve as a refresher for
existing personnel. Training also should
be conducted for new hires.
• Contact a local health department,
environmental management agency,
hazardous waste agency, or chemical
supplier to provide a training session
with school employees that raises their
awareness of using less toxic alternatives
to certain chemicals, chemical
substitutions, green purchasing, and
performing small-scale experiments.


The following resources provide useful additional information on training:
• LAUSD, School Laboratory Chemical Hygiene and Safety Plan (Section III), sd-
oehs.org/docs/CSC/Chemical%20Hygiene%20Plan.pdf
• OSHA, Training Curriculum Guidelines - (Non-mandatory) - 1910.120 App E,

Check It Out
Chemical Management Resource Guide for School Administrators 17 |
Environmental Planning and Community Right-to-
Know Act
The Environmental Planning and Community Right-to-
Know Act (EPCRA) was passed in response to concerns
regarding the environmental and safety hazards
associated with toxic chemicals. EPCRA establishes
emergency planning and chemical reporting
(“Community Right-to-Know”) requirements for Federal,

state, and local governments; Indian Tribes; and
industry. The reporting provisions help increase the
public’s knowledge and access to information on
chemicals at individual facilities (such as schools), their
uses, and accidental releases into the environment. The
EPA sponsors various programs that pertain to chemical
management.
For more information see: EPA, EPCRA Information,

EPCRA.htm?OpenDocument
III.H. Hazard Communication
Hazard communication planning is an
important element in chemical and product
management. Dissemination of information
on the quantity and hazards of hazardous
chemicals and products creates awareness
about the range of chemicals and products
used and fosters proper use and disposal of
these chemicals and products.
Guidelines are listed that schools and
administrators should follow in order to
create a safer school environment for
students and school employees.
• Create a written hazard communication plan
that communicates how chemicals should
be properly managed, stored, handled, and
disposed. The plan should consist of an
updated chemicals and products list,
chemical labeling requirements, MSDS
information, a disposal log, and instructions

on employee training programs regarding
hazards of chemicals and protective
measures. The Appendix offers examples of
hazard communication programs that have
been implemented for various school
districts across the country.
• Work with your local chemical supplier to
help identify specific concerns. Depending
on your location, state and/or federal
hazard communication requirements
specify your responsibility to identify and
address the hazards associated with the
chemicals and products used in your
school facility.

III.I. Spills, Cleanup, and
Disposal
Failing to take necessary safety precautions
may put your school at increased risk of fire,
explosions, and spills that may result
in chemical exposure to students and school
personnel, harm to the environment, and
considerable clean-up costs to the school
district. Hazardous wastes must be disposed
of in accordance with RCRA and other
applicable state and local requirements.
Such requirements generally prohibit any
drain disposal of hazardous chemicals or
“treatment” of hazardous wastes beyond pH
adjustment, and may be far more stringent

than the disposal suggestions provided by
chemical suppliers.
Refer to these resources as recommended guidance for creating your hazard communication plan:
• OSHA Hazard Communication Standard, Title 29 Code of Federal Regulations 1910.1200,

Reminder: Federal OSHA does not have jurisdiction over state and local government employees, including
those in public schools.
• Section III, Summary and Explanation of the Issues and the Provisions of the Final Rule,

• LAUSD OEHS Hazard Communication training presentation,
HazComPresentation.ppt
Chec
k
It Out
| 18 Chemical Management Resource Guide for School Administrators
Chemical Safety Day Program in Minnesota
The Chemical Safety Day Program (CSDP) is a cost-
effective waste management program available to
educational institutions and non-profit organizations
throughout the state of Minnesota. The CSDP has
helped hundreds of high schools, colleges, and
nonprofit organizations in disposing of hazardous
material/waste at a reasonable cost and in an
environmentally responsible way. More information
about the program can be found on the CSDP website
at
Proper chemical disposal can reduce the
costs and management burdens associated
with excess chemicals, including disposal
costs of expired chemicals and the time

required for inventory and storage of excess
and unwanted chemicals, as well as costs of
penalties due to enforcement actions that
may result from improper chemical
management.
Guidelines are provided below that
schools and administrators can follow
in order to reduce the risk of chemical
accidents, improve spill response procedures,
and ensure that chemicals and products in
their schools are safely discarded.
• Create a written emergency response and
spill clean-up and response plan for all
chemicals and products. This plan should
describe what to do and who to contact in
the event of a spill or release, as well as the
location of spill management supplies and
equipment (e.g., spill kits, spill control
materials, fire extinguishers) within the
school. The clean-up and response plan
should include a process for
communicating with students, parents,
teachers, and other staff about the incident,
as well as methods for preventing accidents
and exposures.
• Develop a budget for chemical
management and disposal. Initial costs
may involve hiring a chemical expert and
disposing of accumulated chemicals and
products. A longer-term waste disposal

budget should account for the staff time
necessary to develop and maintain disposal
procedures, the purchase of special
equipment and supplies, the upkeep of
safety equipment (e.g., fume hoods), and
annual hazardous chemical disposal and
staff training.
• Establish a chemical disposal policy that
addresses how unused and outdated
chemicals and products containing
chemicals should be properly removed
from schools, including materials generated
from the cleanup of spills.

A
s shown in the photo above, existing stocks of
outdated, unknown, degraded, and excessive
quantities of hazardous chemicals are present in
many schools posing safety and health risks to
students and school personnel. Identifying and
removing these chemicals is a key step in preventing
accidents. Establish a chemical disposal policy that
addresses how unused and outdated chemicals and
products containing chemicals should be properly
removed from schools.
Photo Credit: Rehab the Lab Program,
Local Hazardous Waste Management,
King County, Washington

Chemical Management Resource Guide for School Administrators 19 |

Disposal Guidelines for School Facilities
Schools must comply with regulations regarding the management, transport, and disposal of hazardous waste.
Schools are required to track the amount of hazardous waste they generate and ensure that all wastes are properly
disposed of according to federal, state, and local requirements. These requirements can affect the way chemicals
and chemical wastes are managed in schools. Subtitle C of RCRA regulates hazardous waste generators.
According to RCRA (40 CFR Part 261), there are three categories of hazardous waste generators (large, small,
and conditionally exempt), based upon the quantity of waste they produce per month. Most schools fall into the
Conditionally Exempt Small Quantity Generator (CESQG) category. A CESQG generates 100 kilograms
(220 pounds) or less per month of hazardous waste, or 1 kilogram (2.2 pounds) or less per month of acutely
hazardous waste. EPA provides definitions of each generator category and its specific requirements at
however, states may have additional requirements for
generators. Refer to these waste management and disposal resources as recommended guidance for your school:
• EPA, Hazardous Waste Management for School Laboratories and Classrooms,

• Idaho Department of Environmental Quality, Idaho Chemical Roundup Waste Management and Disposal at
Schools,
• Nebraska Department of Environmental Quality, School Chemicals and Disposal,

• Florida Department of Environmental Protection, Disposal Guidelines for School Facilities,

The following resources may provide useful additional information in order to reduce the risk of chemical accidents,
improve spill response procedures, and ensure chemicals and products in their schools are safely discarded:
• EPA, Hazardous Waste & Your School, www.epa.gov/ne/assistance/schools/pdfs/mefact.pdf
• King County, Washington, Laboratory Waste Management Guide, Final Report,

• Nebraska Department of Environmental Quality, Guidance Documents: School Chemicals and Disposal,

• Massachusetts Department of Environmental Protection, Massachusetts School Chemical Management
Program, Working Draft,
• Council of State Science Supervisors, Science and Safety: Making the Connection, s-

science.org/downloads/scisafe.pdf
The U.S. National Library of Medicine’s on-line Wireless Information System for Emergency Responders
(WISER) provides assistance in identifying hazardous substances, as well as spill containment advice.
See htt
p
://webwiser.nlm.nih.
g
ov for more information.
Check It Out